Ill. Pattern Jury Instr. (Criminal) 13.78

To sustain the charge of identity theft, the State must prove the following proposition[s]:

[1] [First Proposition:] That the defendant knowingly used any [(personal identifying

information) (personal identification document)] of another person to fraudulently obtain

[(credit) (money) (goods) (services) (property)] [(.) (; and)

Second Proposition: That the value of the [(credit) (money) (goods) (services)

(property)] [(did not exceed $300 in value) (exceeded _________ in value but did not exceed

_______ in value)(exceeded $100,000 in value)]] [(.) (; and)]

[or]

[2] [First Proposition:] That the defendant knowingly used [(personal identification)

(personal identification document)] of another with the intent to commit the offense

of __________ [(.) (; and)]

[or]

[3] [First Proposition:] That the defendant knowingly [(obtained) (recorded) (possessed)

(sold) (transferred) (purchased) (manufactured)] any [(personal identification information)

(personal identification document)] of another with the intent to commit the offense

of ____________ [(.) (; and)]

[or]

[4] [First Proposition:] That the defendant knowingly [(used) (obtained) (recorded)

(possessed) (sold) (transferred) (purchased) (manufactured)] any [(personal identification

information) (personal identification document)] of another knowing that such [(personal

identification information) (personal identification document)] was [(stolen) (produced without

lawful authority)] [(.) (; and)]

[or]

[5] [First Proposition:] That the defendant knowingly [(used) (transferred) (possessed)]

document-making implements to produce [(false identification) (false documents)] with

knowledge that they will be used by the person or another to commit __________________ [(.)

(; and)]

[or]

[6] [First Proposition:] That the defendant knowingly used any [(personal identification

information) (personal identification document)] of another to portray [(himself) (herself)] as

that person, or otherwise, for the purpose of gaining access to any [(personal identification

information) (personal identification document)] of that person, without the prior express

permission of that person [(.) (; and)]

[or]

[7] [First Proposition:] That the defendant knowingly used any [(personal identification

information) (personal identification document)] of another for the purpose of gaining access to

[(any record of the actions taken) (communications made or received) (activities or transactions

of that person)], without the prior express permission of that person [(.) (; and)]

[or]

[8] [First Proposition:] That the defendant knowingly [(used) (possessed) (transferred)] a

radio frequency identification device capable of obtaining or processing personal identifying

information from a radio frequency identification (RFID) tag or transponder with knowledge that

the device will be used by the defendant or another to commit ______________ [(.) (; and)]

[or]

[9] [First Proposition:] That the defendant, in the course of applying for a building

permit with a unit of local government, knowingly provides the license number of a [(roofing)

(fire sprinkler)] contractor whom he does not intend to have perform the work on the [(roofing)

(fire sprinkler)] portion of the project [(.) (; and)]

[(Second) (Third) Proposition: That the victim of the identity theft was an active duty

member of the [(Armed Services or Reserve Forces of the United States) (Illinois National

Guard)] serving in a foreign country.]

If you find from your consideration of all the evidence that [(this proposition) (each one

of these propositions)] has been proved beyond a reasonable doubt, you should find the

defendant guilty.

If you find from your consideration of all the evidence that [(this proposition) (any one of

these propositions)] has not been proved beyond a reasonable doubt, you should find the

defendant not guilty.